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Petitioner has substantiated the amounts in dispute. The
issue for decision is whether these expenses are ordinary and
necessary.
Preliminary Matters
In the stipulation of facts, respondent reserved objections
to several joint exhibits. Specifically, respondent objected on
the basis of relevancy to Joint Exhibit 4-D, a subagent franchise
agreement; Joint Exhibit 5-E, a directory from the Conference of
Personal Managers; and Joint Exhibit 10-J, a breakdown of
available jobs in the entertainment industry. In addition,
respondent objected on the basis of hearsay to Joint Exhibit 7-G,
excerpts from a book entitled "Managers', Entertainers', & Agents
Book"; Joint Exhibit 8-H, excerpts from a book entitled "How to
Manage Talent"; and Joint Exhibit 9-I, an excerpt entitled "But,
What Does a Personal Manager Do?" from the National Conference of
Personal Managers.
Proceedings in this Court are conducted in accordance with
the Federal Rules of Evidence. Sec. 7453; Rule 143. Relevant
evidence means evidence having any tendency to make the existence
of any fact that is of consequence to the determination of the
action more or less probable than it would be without the
5(...continued)
for repairs and maintenance of $129.47 which was neither allowed
nor disallowed by the notice of deficiency and was not mentioned
in the stipulation of facts of stipulation of settled issues.
Thus, we will assume such amount is not in dispute.
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Last modified: May 25, 2011